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Income Tax - Highlights / Catch Notes

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This is a summary of an Income Tax Appellate Tribunal (ITAT) ...


Multinational's transfer pricing & deduction disputes resolved: TP adjustments deleted, regional charges remitted, ad expenses allowed, ESI disallowed.

Case Laws     Income Tax

October 1, 2024

This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing adjustments were deleted for trademark fee, outstanding receivables, and purchase of finished goods transactions based on the application of appropriate methods and factual findings. The regional service charges and accounting support services transactions were remitted to the Transfer Pricing Officer for fresh adjudication after considering the assessee's submissions. The disallowance of 30% advertising and brand-building expenses was decided in favor of the assessee, following earlier years' ITAT orders. The disallowance of employees' contribution to ESI was upheld based on the Supreme Court's decision in Checkmate Services, as the contributions were deposited after the due dates prescribed under the relevant Act.

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